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1.    Introduction

     1. Changes to the legislation concerning money laundering (the Proceeds
         of Crime Act 2002 and the Money Laundering Regulations 2003),
         have broadened the definition of money laundering and increased the
         range of activities caught by the statutory framework. As a result, the
         new obligations now impact on areas of University business and
         require universities and colleges to establish internal procedures to
         prevent the use of their services for money laundering.

2. Scope of the Policy

     1. This Policy applies to all University employees and aims to maintain the
         high standards of conduct which currently exist within the University
         by preventing criminal activity through money laundering. The Policy
         sets out the procedures which must be followed (e.g. the reporting of
         suspicions of money laundering activity) to enable the University to
         comply with its legal obligations.
     2. The Policy complements the University’s Anti-Fraud and Anti-
         Corruption Strategy.

3.    What is Money Laundering?

     1. The term Money Laundering includes concealing, disguising,
         converting, transferring or removing criminal property from the UK,
         plus acquiring, using or possessing criminal property, or entering into
         arrangements to help another person in the acquisition, retention, use
         or control of criminal property.
     2. Criminal property is a person's benefit from criminal conduct where the
         alleged offender knows or suspects that the property constitutes or
         represents such a benefit. It is specifically provided in the legislation
         that concealing or disguising criminal property includes concealing or
         disguising its nature, source, location, disposition movement or
         ownership or any rights with respect to it.
     3. It does not have to be in the UK; criminal conduct is conduct that
         would be an offence in the UK if it is committed there, i.e. it can be
         committed abroad and still be reportable in the UK.

4.    What are the obligations of the University?

     1. The Money Laundering Regulations 2003 came into force on 1 March
         2004, and under the terms of the Regulations the university must,
         when engaged in “relevant business”, (as defined in Reg.2(2) of
         Money Laundering Regulations) adopt procedures noted in 4.2 – 4.5
         below. For the university these procedures must be followed for any
         sales of goods involving acceptance of a total cash payment of
         €15,000 or more. (This excludes tuition fees as the provision of
         education for a fee is the provision of a service). For all other
         transactions please see para. 4.5 below only.
     2. Appoint a Money Laundering Officer (MLRO) to receive disclosures from
         employees of money laundering activity. The MLRO for the university
         is the Head of Finance Mr Kevin Wright.
 3. Be satisfied as to the identity of its customer. When dealing with
     business, the use of official stationery and invoices is normally
     sufficient to confirm the identity of the customer. When dealing with
     individuals, we should obtain photographic evidence such as a
     passport or driving licence.
 4. Maintain adequate records of the transaction and identity of its
     customer, and where appropriate documentation confirming the
     identity of the customer, and a full audit trail of the transaction/(s),
     must be retained for a period of no less than 5 years.
 5. Have a mechanism for reporting possible indications of money
     laundering. Any member of staff who has reason to believe money
     laundering has taken place, or who has concerns or suspicions
     regarding possible indications of money laundering must disclose this
     to Mr Kevin Wright without delay. If Mr Kevin Wright considers the
     information to give knowledge or suspicion of money laundering, he
     must forward the information to the Serious Organised Crime Agency.

Updated 14/12/06.

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